FHA Appraisal Audit/review - Punishment

[KenAZ]

FHA has always been overly concerned about minor issues. The only difference now is that they audit far less reports than they used to. They used to audit 10%.

 

[LordofTexas]

What kind of appraiser would require this of another appraiser? Was it reviewed by an appraiser?

Exactly Amy, but it is not our Peers that govern us; it is the Chosen.

 

[Mile High Trout]

In this day of automation, you simply have to understand how they do things. The reviewers coorelate data from available sources. You'd better start double checking public records for size, because you know the reviewers do that. You're walking the line of legal permissibility and unpermitted addition issues. Those are hot topic issues at this time.

If you've explained enough, you'll have better luck passing through reviews. I agree that boilerplate is right out.

If you post specific copy pastes of your various total market overviews, you're less likely to be challenged on comparables. Post the whole market picture, the filtered market picture, and clearly describe your search peramiters. If you say there were no similar comps in that unfiltered body of data, you're far more defensible than if you did not post whole market data within your report. I just copy the 1 liner cover pages or results lists from MLS research. And copy another one filtered, and another one, and another one, etc. You've got to understand the reviewers focus on process compliance, because they don't have the same data access as you do, most likely. If all the reviewers have is report content, and they're taking action based on that, I think the days of 'it's in the workfile' are just about over.

I do non stop FHA work. For dirt cheap minimums. Jtip made sure I get more FHA work than the next guy. My nickname is tool jr. Still trying to work my way up though.

 

[Delta85]

1. Not including "HUD/FHA" in the intended users statement -- my bad, but does this warrant 21 hours of coursework? I feel a warning should suffice? But it seems FHA would rather punish you and take your time and money.

2. "Comparable # 4 reported as having 3 bedrooms and 2 baths - MLS states 3 bedrooms 2.75 baths" -- the reviewer was wrong on this one, however I was not allowed to appeal.

3. Site shape reported to be "Irregular". Appraiser is required to list all site dimensions beginning at the frontage -- ok, my bad again, but the correct site size was reported, just not the actual dimensions as it was very irregular shaped. Does this warrant 21 hours of classes? $400 for the classes? and $50 to take a proctored exam for the USPAP course test?


1. HUD/FHA is an intended user and it does say in the hand book to state that.

2. 2.75 baths IS 3 full baths.

3. You have to do what you are required, in writing, to do. Those are called assignment conditons.

So yes, when taken in context with your spa problem you probably did merit a slap on the wrist. Sorry.

Unless he had a prior record of mistakes or violations nothing he posted warrants 21 hours of classes and $400 in expenses. Period.

A warning was warranted.

 

[Delta85]

It's scary that the OP was unable to appeal or speak to anyone. Sounds like he had reasonable explanations for at least a couple of the infractions.

 

[Mile High Trout]

It's scary that the OP was unable to appeal or speak to anyone. Sounds like he had reasonable explanations for at least a couple of the infractions.

Maybe more pictures of his subject and comps could have helped. Perhaps some simple copy pastes of all available data the appraiser had to work with.

I'm just guessing here... HA

The point is; If you leave the reviewers guessing, expect the worst.

Fees need to go up, not down. Regulatory compliance, and secondary market scrutiny is going way way up. Fees need to follow. Minimum standards are on the up and up, whether appraisers agree with it or not. I too, learned appraising in a different day and age when all this extra work was not required. And I've watch the competition spring up, and fall down, ever since. I for one, have my own minimum standards, and they relate to reviewers more than originators. If I can pass a stringent review, that's good enough for me. Measurable adjustments are not all they're cracked up to be. You have a good feel for market values, or you don't. Canned verbiage is for the appraiser imposters, not the astute professionals. Outsourced appraisal form filling and such is for the complete outright imposters. If you can talk shop, you can type that into reports. Never use canned verbiage except for introductory statements, and do take the time to explain every friggin little thing in detail. As default rates climb, so does the nature of review become more stringent and demanding. Secondary market review staff gets about twice the hourly pay as an appraiser who takes the time to do it right, by today's standards. As usual in real estate; the proof usually lies in the price.

 

[Delta85]

Maybe more pictures of his subject and comps could have helped. Perhaps some simple copy pastes of all available data the appraiser had to work with.

According to the OP he had extensive comments in the report. I'll take his word they were more than enough. 100 photos would not have helped explain why his GLA differed from MLS GLA or that even with extended search parameters a similar home with a spa could not be located.

 

[Mile High Trout]

Fail. You've imposed a limitation, and now you have to live with it.

Photos help overall confidence in the appraiser, and his conclusions.

Your mechanical approach to appraising, could be your demise.

And it probably can't happen soon enough.

 

[Delta85]

Fail. You've imposed a limitation, and now you have to live with it.

Photos help overall confidence in the appraiser, and his conclusions.

Your mechanical approach to appraising, could be your demise.

And it probably can't happen soon enough.

Stop being so defensive. If you like including 100 photos have a blast. IMO it's overkill. Your attempts to make those not including 100 photos look less competent wreaks of desperation. 100 photos is silly for a standard report and I am sure your clients see it and go "WTF?"

Just because I do not include 100 photos does not make my reports mechanical and your failure to see this makes you the Felix Unger of appraising.

 

[Digger88]

If you think this is bad, wait til the GSE's (Fannie Mae and Freddie Mac) blacklist Appraisers for similar issues based on their UCDP AQM analysis.

Rather than a class and fine, your appraisal career will be over.

The worst part is the GSE's have no accountability for their actions.

you know? suddenly all my sketches match tax records and all of my adjustments are the same. wonder why that is?